21 October 2011

EBF response to the IASB's ED of proposals to adjust the Mandatory Effective Date of IFRS 9

The EBF welcomes the postponement of the effective date of IFRS 9 Financial Instruments. It is estimated that the IFRS 9 would require at the minimum two to three years' implementation time and significant IT investments. The implementation time depends on the nature of the changes proposed, in particular in relation to the part of the standards which are not yet finalised. Considering that only phase 1 of the IFRS 9 project is completed, and may still be subject to amendments resulting from subsequent phases and convergence discussions, as well as the uncertainty related to phases 2 and 3, it is impossible to evaluate at this stage the exact time and effort that will be necessary for implementation.

Considerations should also be given to the alignment of the effective dates with other standards such as IFRS 4 which are still under discussion, and it is not clear whether these will be ready for implementation as of January 2015. Until all these projects are completed, it is not possible for an entity to set its accounting policies and decide on financial instruments’ classification and hedge designation.

It also has to be taken into account that in some jurisdictions, the implementation of the standard can only start after an endorsement process has been completed, which may take an additional six months from the time of the issuance of the final standard by the IASB.

The EBF would therefore like to suggest that instead of setting a fixed effective date, a minimum of three years' implementation time should be given after the completion of all phases of IFRS 9.

The EBF believes that a need for a high-quality standard should outweigh the importance of concluding the project within an artificial timeline. However, the EBF believes that an earlier adoption of the new requirements of IFRS 9 on the presentation of movements in the fair value of liabilities designated at fair value relating to own credit should be considered. This would significantly improve the quality of IFRS in the short term.

The ED proposes not to extend the relief for restating comparatives. The EBF does not agree with the proposal that the implementation of IFRS 9 should require full retrospective restatement of comparatives. It is not believed that this would improve the usefulness of the information for users.

The EBF supports retrospective application, providing that an entity should assess the business model based on the facts and circumstances that exist at the date of initial application without restatement of comparatives, except where there is a clear justification for prospective-only adoption.

Full paper

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